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Health Freedom NZ

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Petitioning Ministry of Health Hon Jonathan Coleman

Keep access to nutrients in NZ that have a proven safety record and therapeutic benefit

Julia Rucklidge; Christchurch, New Zealand

Something very concerning is developing in New Zealand. It is not unique to NZ – it has already happened in Australia, has been happening in Europe, and it will likely happen in the U.S. and Canada. Under the guise of regulating Natural Health Products (NHPs) to ensure their safety, the NHPs are actually being severely restricted.

In NZ, the government is passing legislation called the Natural Health and Supplementary Products Bill that will limit access to minerals and vitamins.

While safety and efficacy are important, this Bill will ban for sale many NHPs that New Zealanders rely on for their health. In so doing, it will ban formulas for which there is scientific evidence of benefit for mental health, including the products that Prof Julia Rucklidge has been studying at the University of Canterbury for the last decade. This research has demonstrated the effectiveness of micronutrients for the treatment of a variety of psychological/psychiatric symptoms ranging from ADHD to stress to PTSD to mood disorders. The research has also documented a superb safety record of the micronutrients.

Unfortunately, the NZ Ministry of Health has taken a ‘single ingredient approach’ to the development of the “Permitted Ingredient List”, a list of the 5545 ingredients that are currently allowed in an NHP but all with specified doses. As such, it is extremely limiting and not reflective of how nutrients are consumed to be of greatest benefit to health. The ‘single ingredient approach’ that is behind the development of the list does not reflect the fact that when one consumes ingredients together, one can tolerate different doses safely compared to when an ingredient is consumed alone.

A perfect example of how guidelines based on single nutrients can be misleading is folate. Folate has an upper limit dose that is set based on the fact that excessive consumption can mask a B12 deficiency. However, if one consumes a multi-ingredient formula with both folate and B12, then folate levels can be much higher without adverse effects. This single ingredient approach the NZ government is following is outdated.

An additional disastrous implication of this single-nutrient framework for the Bill is this: if a product exceeds a specified dose, even for one ingredient, then the entire product cannot be sold in NZ. There are also blacklisted ingredients, ingredients that cannot be included in any NHP. Vanadium, a trace mineral contained in many vegetables and cereals, is one example; vanadium is useful in building strong bones and teeth, and also has a role in regulating blood sugar. Why would it be banned?

To make things even more complicated, the recommended definition of an NHP means that it cannot include a medicine. In NZ, vitamin D is a medicine if it is consumed above 25mcg. In other words, if an NHP has more than 25mcg (1000 IU) of Vitamin D, the entire product would be banned as the Medicines Act trumps the Natural Health and Supplement Products Bill. This is also the upper limit dose specified in the permitted ingredient list. Yet many people choose to take more than 1000 IU of vitamin D, and the Dietary Reference Intakes of North America specify that it is safe to take 4000 IU/day (that’s the tolerable Upper Level), and the No Adverse Effect Level is 10,000 IU/day. Why would a nation restrict intake to 1000 IU if there is no apparent risk?

Another example is selenium. If a product has a daily dose greater than 150mcg of selenium, it cannot be included in an NHP. Eating five brazil nuts would exceed this daily dose. Is that logical?

There is some evidence that the result could be tragic: over 10 years ago when Health Canada shut down clinical research in this area and, more importantly, closed the border so that Canadians could not buy a mineral and vitamin formula for several years, many law-abiding Canadians were enormously stressed at having to break the law and sneak it across the border from the U.S. (where it is manufactured). In addition, two adults committed suicide. In both cases (which were confirmed in court by the head of the Western Canadian Division of the Canadian Mental Health Association), the families said these people chose suicide rather than being forced to return to psychiatric medication when they could not access the nutrient formula that had brought them good mental health.

The Permitted Ingredient List needs to be reviewed in light of this research and unforeseen outcomes. This Bill, because of the definition of what a natural health product is and the dose restrictions identified on individual ingredients, will result in these products being inaccessible to New Zealanders which will directly lead to harm given that consumers will no longer be able to purchase these nutrients to keep themselves well. This Bill is not proportional with the low level of risk associated with NHPs. The only truly necessarily regulation that is required is ensuring that supplements have exactly what they say they have in them.

NB: The NZ Journal of Natural Medicine regularly covers issues relating to freedom of choice in healthcare. If you are not already a reader or subscriber, please visit www.naturalmedicine.net.nz/shop/ to access free samples of our current issue and back issues or purchase printed copies or a subscription.